William Kale - Page 2

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               The issues for decision are:  (1) Whether petitioner is                
          collaterally estopped from denying that he received bribe income            
          during the years in issue. We hold that he is not.  (2) Whether             
          petitioner received unreported bribe income during the years in             
          issue.  We hold that he did. (3) Whether petitioner is liable for           
          additions to tax for fraud pursuant to section 6653(b).1  We hold           
          that he is.  (4) Whether respondent is precluded from assessing             
          tax for the years in issue due to the running of the statute of             
          limitations.  Due to our holding in issue 3 above, we hold that             
          she is not.                                                                 
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and attached exhibits are incorporated             
          herein by this reference.  At the time the petition herein was              
          filed, petitioner resided in Pompano Beach, Florida.                        
          Petitioner                                                                  
               Petitioner received a Bachelor of Science degree in                    
          accounting from the Drexel Institute of Technology in 1949.  From           
          1953 to January of 1981, petitioner was employed as a Revenue               
          Agent with the Examination Division of the Philadelphia Office of           
          the Internal Revenue Service (IRS).  As a revenue agent,                    
          petitioner was responsible for conducting examinations of filed             


               1 All section references are to the Internal Revenue Code in           
          effect for the taxable years in issue, and all Rule references              
          are to the Tax Court Rules of Practice and Procedure, unless                
          otherwise indicated.                                                        



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